Supplementary memorandum by the Campaign
to Protect Rural England (CPRE) (AH 57(a))
INTRODUCTION
1. At the end of the second evidence session
for this inquiry on 6 December the Chairman invited CPRE to submit
a written response to the question "Do local planning authorities
have sufficient power to ensure housing is built to high environmental
standards?" This note addresses that question.
2. We would also like to take this opportunity
to clarify CPRE's position on the issue of housing numbers and
development plans, as well as to raise questions about the implications
of draft Planning Policy Statement (PPS) 3 Housing which was issued
for consultation the day before the Committee's second evidence
session.
"Do local planning authorities have sufficient
power to ensure housing is built to high environmental standards?"
3. CPRE does not believe that planning authorities
have sufficient powers in this area. Some local authorities may
have a better record than others but we do not believe that recent
Government pronouncements are likely to achieve very much by way
of improving performance across the board. Indeed, we fear that
the current proposals could actually lead to a deterioration in
the ability of local authorities to require high environmental
standards in the provision of new housing. This could make the
environmental `footprint' of new housing extend much further than
it currently does, as well as reducing the long term affordability
of running a home to the detriment of those on low or moderate
incomes.
4. Draft PPS 3 is particularly weak in this
regard. For example, it contains a section on "greening the
residential environment" but this places no requirements
on local authorities to ensure this is delivered on the ground.
The draft PPS merely states that "local planning authorities
should encourage applicants to apply principles of sustainable
and environmentally friendly design and construction", and,
in particular, to encourage them "to apply the proposed Code
for Sustainable Homes" (paragraph 39).
5. Given the Government's apparent intention
to rely largely on private, market housing to address what is
sees as the shortage in supply, it is disturbing that it is proposing
to make the Code for Sustainable homes voluntary for private development
(ie that which does not enjoy public funding). We believe that
applying sound principles of sustainable and environmentally-friendly
design and construction to new housing development should be mandatory,
not optional. This will be essential if we are to meet commitments
in the UK Strategy for Sustainable Development. It will also be
essential for the Code to cover a wider range of issues. We believe
it should, as a minimum, incorporate assessment of:
— materials sourcing (eg aggregates:
whether primary, secondary or recycled/re-used, distance transported
to the sites and by what means of transport);
— accessibility to public transport
(and preferably also to the potential for households' daily needs
to be met on foot); and
6. In addition to these issues, CPRE notes
that WWF has recently expressed a fear that the proposed Code,
as currently drafted, could actually lower the standards currently
required of new, publicly funded housing.
7. There is a particular difficulty in securing
high environmental standards in new housing because certain important
matters fall under building regulations (eg thermal efficiency)
and others under planning controls (eg the external design of
buildings, layout and orientation of development on site), but
all significantly affect environmental performance. PPS1, issued
earlier this year, states that planning policy should not overlap
with matters dealt with under other legislation or administered
by different regimes (eg building control). We strongly believe
that this position has become a real barrier to progress. There
is also anecdotal evidence (as recently discussed by the Environmental
Audit Committee as part of its current inquiry) that the effectiveness
of Building Control regulations is being affected by a shortage
of resources and skills, pressure to cut costs and a lack of enforcement.
An integrated approach is urgently needed, especially since building
control is often a relatively late consideration in the development
and planning process. This could help co-ordinate and combine
planning and building controls in order to achieve the higher
environmental standards which are so necessary.
HOUSING NUMBERS
AND DEVELOPMENT
PLANS
8. We would like to add a point of clarification
on our view as to the number of new homes that are needed in England.
We strongly support the plan-led system, through Regional Spatial
Strategies (RSSs) and Local Development Frameworks (LDFs), as
a basis for agreeing the number of homes that should be built
and their distribution. Hence, the reference in our oral evidence
to the 170,000 homes provided for in adopted/emerging Regional
Spatial Strategies as representing a level of annual housing supply
we could broadly subscribe to.
9. CPRE will not always agree with the precise
figures arrived at in every region, and there will inevitably
be issues concerning the distribution and precise balance between
brownfield and greenfield development. We firmly believe, however,
that if the plan-led system is to be credible, effective and command
public confidence any proposed changes in the levels of housing
provision should come forward—and be subject to rigorous
examination—through the established process. The Government's
new planning system lays great emphasis on the importance of a
credible evidence-base for policy and decisions, something we
strongly support. "Targets" for housing supply imposed
from the centre, with little or no reference to contextual evidence
of need and environmental implications, are inconsistent with
this approach. Their effect is not only misguided, but actively
damaging to the integrity of the plan-led system.
10. We consider that projected household
growth should be taken into account in determining housing provision.
Household formation should not be seen as directly correlating
with the number of new homes needed, however, since it is important
to compare the total number of households with the dwelling stock,
as well as to take into account other objectives. In particular,
we need more effective action to reduce the number of empty homes
(and particularly the 300,000 or so long term empty properties),
consider scope for conversions from other types of buildings,
and reduce levels of under-occupancy. Before building new homes.
we need to make much better use of the potential offered by these
sources.
DRAFT PPS3
11. We would also like to urge the Select
Committee to consider including an assessment of draft PPS3, published
on 5 December, in its deliberations. From our initial reading
of the draft we believe that certain important aspects would benefit
from the Committee's scrutiny. We suggest the Committee considers
holding a further evidence session under the current inquiry,
or a further inquiry, to consider draft PPS 3. In our view, key
issues to address include:
— questions over the practical application
of the clear priority for brownfield over greenfield sites, set
out in the draft and reinforced in comments by the Planning Minister
on its launch, given the proposed removal of local authorities'
ability to phase release of sites in the first five years of planned
provision;
— tensions between the Government's
priority for brownfield sites and the explicit discouragement
of local authorities from making assumptions regarding the supply
of housing on (brownfield) windfall sites, and how these could
be resolved;
— whether the proposed return to a
five-year housing land supply rule risks a regression to "planning
by appeal" which plagued planning for housing prior to publication
of revised PPG3 in 2000, and how this could be avoided;
— whether, given the large proportion
of new housing now built on small urban sites, the retention of
an indicative site threshold for affordable housing requirements
will significantly reduce the potential supply of affordable housing,
and whether abolition of thresholds altogether would be preferable;
— what needs to be done to ensure that
Sustainability Appraisal of plan documents and site allocations
is sufficiently effective and robust to deliver genuinely sustainable
patterns of development; and
— issues surrounding the proposed sub-regional
Housing Market Areas: draft PPS3 includes a table illustrating
how different approaches might apply in different Housing Market
Areas but appears to excludes the possibility that in some areas
of high demand, such as Areas of Outstanding Natural Beauty, a
low or no growth option which focuses on meeting local needs might
be the most appropriate way forward.
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